Federal Communications Commission DA 15-1349
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matters of
Telecommunications Relay Services and 
Speech-to-Speech Services for 
Individuals with Hearing and Speech Disabilities
Structure and Practices of the Video Relay Service 
Program
Internet-Based Telecommunications Relay Service 
Numbering
Waiver of Sections 64.613(a)(4), 64.613(b)(2) and 
64.623(c) of the Commission’s Rules to Permit 
VTCSecure and the MITRE Corporation to Access 
the TRS Numbering Directory
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CG Docket No. 03-123
CG Docket No. 10-51
WC Docket No. 10-191
ORDER
Adopted:  November 23, 2015 Released: November 23, 2015
By the Chief, Wireline Competition Bureau:
1. By this Order, the Wireline Competition Bureau waives on its own motion sections
64.613(a)(4), 64.613(b)(2) and 64.623(c) of the Commission’s rules
1
to permit VTCSecure,
2
which serves 
by contract as administrator of the Video Relay Service (VRS) Access Technology Reference Platform
(reference platform),
3
and the MITRE Corporation (MITRE), which is under contract to perform research 
and development compensated from the Telecommunications Relay Services (TRS) Fund,
4
to access the 
TRS Numbering Directory to the extent necessary to carry out assigned tasks related to their contractual 
responsibilities. Clarifying both entities’ eligibility to access the directory under these terms will 
facilitate the effective performance of their respective duties.
                                                     
1
Section 64.613(a)(4) provides that “[o]nly the TRS Numbering Administrator and Internet-based TRS providers 
may access the TRS Numbering Directory.”  47 C.F.R. § 64.613(a)(4).  Sections 64.613(b)(2) and 64.623(c) each
provide that the TRS Numbering Administrator shall administer the numbering directory “pursuant to the terms of 
its contract.” 47 C.F.R. §§ 64.613(b)(2), 64.623(c).
2
See VTCSecure, www.vtcsecure.com (last visited Oct. 20, 2015).
3
See 47 C.F.R. § 64.619. 
4
SeeMITRE Corp., www.mitre.org (last visited Oct. 20, 2015). The MITRE Corporation is a private, not-for-profit 
corporation that operates federally funded research and development centers (FFRDCs).  The FCC contract is, more 
specifically, an order placed with an FFRDC operated by MITRE under the sponsorship of, and under contract with, 
the U.S. Department of Health and Human Services.
Federal Communications Commission DA 15-1349
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2. In 2013, the Commission adopted reforms “to improve the structure, efficiency and 
quality” of VRS.
5
These included the creation of a “reference platform” for VRS access technologies, 
which provide the various configurations of software and equipment implemented by VRS providers to 
enable their customers to place and receive VRS calls.
6
The purpose of the reference platform is to 
provide “a concrete example of a standards specific VRS access technology implementation” that serves
as a benchmark of interoperability and portability for all VRS access technologies. The platform will be 
made publicly available,
7
allowing providers “to ensure that any VRS access technology they develop or 
deploy is fully compliant with [Commission] interoperability and portability requirements.”
8
Ultimately, 
interoperability with the reference platform will be “a minimum condition for a provider’s VRS access 
technology to be in compliance with [Commission] rules” and for “receiving compensation from the 
[TRS Fund].”
9
3. The Commission also decided in 2013 to allocate TRS funding for research and 
development (R&D) aimed at “ensuring that TRS is functionally equivalent to voice telephone services 
and improving the efficiency and availability of TRS.”
10
Rather than allow individual providers to claim 
this funding, the Commission determined that a third party should be engaged to carry out R&D under 
contract with the Commission.
11
4. The Commission’s Managing Director has selected and entered into a contract on the 
Commission’s behalf with VTCSecure to develop and implement the reference platform
12
and with 
MITRE to conduct R&D.
13
Each of these entities may be hindered in the performance of its contractual 
responsibilities if it is barred from accessing the TRS Numbering Directory, the database that maps VRS 
users’ telephone numbers to Internet Protocol addresses to enable VRS call completion.
14
  Access to the 
directory could enable VTCSecure to perform more effectively various duties that relate to the
development and testing of the platform, as well as other tasks that may arise in the course of its 
responsibilities as reference platform administrator.  Such access could similarly assist MITRE in 
carrying out various of its assigned R&D tasks, such as working to improve VRS call routing capabilities. 
                                                     
5
See Structure and Practices of the Video Relay Services Program et al., CG Docket No. 10-51 et al., 28 FCC Rcd 
8618, 8620, para. 1 (2013) (VRS Reform Order).
6
See id. at 8644-47, paras. 53-61.
7
See id. at 8646, para. 57.
8
Id. at 8644, para. 53.
9
Id. at 8646, para. 58.
10
Id. at 8630, para. 22.
11
Id. at 8629-30, paras. 20-22.  Although the VRS Reform Order directed the Managing Director to enter into an 
arrangement with the National Science Foundation for this purpose, id. at 8624 para. 8, 8630, para. 22, the 
Commission later broadened the Managing Director’s discretion to consider alternatives.  See Technology 
Transitions et al., GN Docket No. 13-5 et al., Order, Report and Order and Further Notice of Proposed Rulemaking, 
29 FCC Rcd 1433, 1480-81, paras. 141-43 (2014).  The Managing Director has retained MITRE to conduct such 
R&D. See FCC Announces Release of an Auto Call Routing Implementation Guide “Cookbook” for Direct Video 
Communications, Public Notice, DA 15-1312 (rel. Nov. 18, 2015) (MITRE Public Notice).
12
See FedBizOpps.gov, www.fbo.gov (search “Keyword/Solicitation #” for “FCC14R0012”). VTCSecure’s 
activities as administrator of the reference platform are compensable from the TRS Fund. See 47 C.F.R. § 
64.619(b)(2).
13
See MITRE Public Notice.
14
See 47 C.F.R. § 64.613(a)(1), (a)(2); see also Telecommunications Relay Services and Speech-to-Speech Services 
for Individuals with Hearing and Speech Disabilities et al., CG Docket  No. 03-123 et al., Report and Order and 
Further Notice of Proposed Rulemaking, 23 FCC Rcd 11591, 11612, para. 49 (2008) (2008 VRS Order). 
Federal Communications Commission DA 15-1349
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Yet neither VTCSecure nor MITRE is an “Internet-based TRS provider” permitted access to the directory 
under section 64.613(a)(4) of the Commission’s rules.
15
       
5. The Commission may waive a provision of its rules on its own motion “if good cause 
therefor is shown.”
16
A waiver is appropriate where “particular facts would make strict compliance 
inconsistent with the public interest” or, in other words, where “special circumstances warrant a deviation 
from the general rule and such deviation will serve the public interest.”
17
This standard is clearly met 
here. The primary purpose of allowing only TRS providers and the TRS Numbering Administrator to 
access the directory is to protect “the security of the central database and privacy of the data contained 
therein.”
18
Both VTCSecure and MITRE operate under detailed contractual agreements that include 
safeguards to protect non-public information from unwarranted disclosure, and both perform their 
responsibilities in close coordination with, and under the supervision of, Commission staff. Permitting 
these entities to access the TRS Numbering Directory to the extent necessary to carry out their contractual 
obligations would therefore be consistent with the security and privacy interests that motivated the 
Commission to withhold access to the directory from the general public.  Moreover, declaring VTCSecure 
and MITRE eligible to access the directory will further the public interest by enabling each entity to fully 
perform the unique responsibilities associated with its role. For VTCSecure, these responsibilities include
developing and testing the reference platform and providing technical support to VRS providers, 
developers and end users, and for MITRE, these include various research and development tasks aimed at 
improving the overall state of VRS and other forms of TRS.  
6. For these reasons, we waive section 64.613(a)(4) to the extent it prohibits either 
VTCSecure or MITRE from accessing the TRS Numbering Directory for the purposes assigned by the 
Commission to achieve fulfillment of each entity’s contractual obligations. We also waive sections
64.613(b)(2) and 64.623(c) as to the TRS Numbering Administrator, Neustar, to the extent either of these
provisions separately prohibits Neustar from granting VTCSecure or MITRE access to the directory.  In 
granting this relief, we remind both VTCSecure and MITRE of their obligations to comply with the terms 
of their contracts and with applicable Commission requirements. 
7. ACCORDINGLY, IT IS ORDERED that, pursuant to sections 1-5 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 151-155, and sections 0.91, 0.291, and 1.3 of the 
Commission’s rules, 47 C.F.R. §§ 0.91, 0.291, 1.3, sections 64.613(a)(4), 64.613(b)(2) and 64.623(c) of 
the Commission’s rules, 47 C.F.R. §§ 64.613(a)(4), 64.613(b)(2), 64.623(c), ARE WAIVED to the extent 
indicated herein.
                                                     
15
See 47 C.F.R. § 64.613(a)(4) (“Only the TRS Numbering Administrator and Internet-based TRS providers may 
access the TRS Numbering Directory.”).
16
47 C.F.R. § 1.3.
17
Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990). 
18
2008 VRS Order, 23 FCC Rcd at 11617, para. 67; see also id. at 11614, para. 55 (dismissing as presenting 
“significant security risks” a proposal to have end users directly provision information to the TRS Numbering 
Directory). 
Federal Communications Commission DA 15-1349
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8. IT IS FURTHER ORDERED that, pursuant to section 1.102(b) of the Commission's 
rules, 47 C.F.R. § 1.102(b), this Order SHALL BE EFFECTIVE upon release. 
FEDERAL COMMUNICATIONS COMMISSION
Matthew S. DelNero
Chief
Wireline Competition Bureau